What makes advisors & referral partners different from an ordinary filing?
An adviser who refers a cross-border matter stays responsible for the domestic file, which makes the scope boundary — and who signs what — the first thing to agree in writing. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
Will you try to take over my client relationship?
No. The referral is scoped to the cross-border element and nothing else. Before anything begins we set out in writing which return, disclosure or position sits with us, which stays with you, and who signs each document. Your client keeps you as their adviser for the domestic file; we are engaged only for the part you have named. Correspondence can be routed through you if you prefer it that way, or sent direct with you copied — that is decided at the outset rather than assumed. When the defined work is finished, the engagement ends. If your client later asks us about something outside that scope, we tell you before we answer.
Who signs the return when I refer a cross-border client?
Whoever prepared it. That is the practical reason to write the boundary down: the preparer of each return carries the responsibility that goes with it, and a referral does not shift that responsibility to the other adviser by implication. Where we prepare a foreign return, we sign it and we answer for it. Where you prepare the domestic return, you sign it and answer for it, and you decide what, if anything, from our work you rely on. If one return depends on a figure from the other, we say so in writing and identify the figure, so there is a record of what was supplied and when.
Can I give my client a fixed price before I refer them?
Yes, provided the scope is settled first. We read the documents your client already holds, identify what actually has to be filed or established, and put a figure in writing before any work starts. You can pass that figure on as it stands. Where the papers do not yet show whether a further filing is required, we say which question is open and price the work that answers it separately, rather than quoting a range that later moves. That way you are never in the position of having quoted your client one number and having to go back to them with another.
What am I still responsible for after making a referral?
The domestic file, unless you have expressly handed some part of it over. A referral is not a transfer of the engagement. In practice the adviser who holds the main relationship remains responsible for the deadlines on their own returns, for the records supporting them, and for telling the client when a cross-border fact changes something domestic. Our scope note names the specific documents we produce and the specific questions we answer; anything not named remains yours. Where our work changes a domestic figure — a credit, a basis, an amount reported — we send the figure and the reasoning to you in writing, so the change is on your file as well as ours.
Do I have to hand over my whole client file?
No. We ask for the documents relevant to the cross-border question and nothing more: the papers that establish residence or presence, the ones showing the foreign income or asset, and any prior filings in the other country. If a domestic return matters to the analysis we will ask for the relevant pages rather than the file. Your client's remaining records stay with you. Where you would rather send extracts than originals, that works, provided the extracts carry the dates and the figures the position turns on. Documents are exchanged on secure cloud software and signed electronically.
How should I explain the referral to my client?
Plainly, and in writing if you can. What tends to reassure a client is knowing three things: which piece of their affairs is going to a specialist, that their existing adviser is staying in place, and what it will cost. We can supply a short scope note for you to forward, setting out the work, the boundary and the fixed fee, before your client is asked to agree to anything. Clients who feel they have been passed on are usually clients who were never told what stayed where. Questions from either of you can go to +1 (416) 619-0068.
What is a permanent establishment, and how easily do we create one?
A taxable presence in another country under the treaty — typically a fixed place of business such as an office, branch, factory or workshop, or a dependent agent habitually concluding contracts on your behalf. Some treaties add a services test measured in days. Purely preparatory or auxiliary activity is excluded, but that carve-out is narrower than it sounds: one senior employee working from home in the other country, with authority, has been enough. See business profits and permanent establishment.
How does cross-border tax planning work?
It starts with facts rather than structures: which countries have a claim on you, what each one taxes, and where the two overlap. From there the decisions are about order and timing — which country taxes first, where relief is claimed, and whether a filing or a certificate has to be in place before money moves rather than after. Most of the value is in the sequencing, because relief claimed late is usually relief recovered slowly. See international tax planning.
